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evidence. See Watson v. Commissioner, T.C. Memo. 1988-29. If no
other documentation is available, we may accept credible
testimony of a taxpayer to substantiate a deduction. Watson v.
Commissioner, supra.
Moreover, expenses that are incurred before the commencement
of business operations constitute preopening or startup expenses
and are not deductible under section 162. See Jackson v.
Commissioner, 864 F.2d 1521, 1525-1526 (10th Cir. 1989), affg. 86
T.C. 492 (1986); Hardy v. Commissioner, 93 T.C. 684, 687-693
(1989); Goodwin v. Commissioner, 75 T.C. 424, 433 (1980), affd.
without published opinion 691 F.2d 490 (3d Cir. 1982).
Generally, petitioner failed to introduce any reliable
written substantiation for his claimed traveling expenses.
Petitioner testified that he kept receipts that substantiated his
traveling expenses, but that the receipts were stolen.
Petitioner’s testimony regarding his traveling expenses was
generally vague and unconvincing. At times he was almost
hysterical. Nevertheless, his presentation was at best a
dramatic effort to explain his failure to provide substantiation
of his claimed travel expenses. Petitioner also failed to
demonstrate that he attempted to reconstruct these expenses. He
did not present testimony of any other witness, except his wife,
to substantiate his own testimony. Mrs. Hooli’s testimony was
brief and generally in the form of responses to her husband’s
leading questions. We cannot give this unconvincing testimony
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